MOSCOW -29th July -EBM NEWSDESK ANALSYIS – Nick Staunton
Brussels is preparing its largest corporate blacklist since the invasion of Ukraine. The scale is dramatic, but Europe’s real problem is no longer identifying Russian enablers. It is enforcing the rules without granting exemptions when they become economically inconvenient.
The European Union is preparing to sanction more than 1,600 companies accused of supporting Russia’s war against Ukraine, in what would be the largest number of businesses blacklisted in a single European sanctions package.
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SubscribeThe companies reportedly generate more than $20 billion in combined annual revenue and employ over 265,000 people. If every EU member state approves the proposal, it would increase the number of entities sanctioned during the war by around 50%. Officials hope to secure agreement when foreign ministers meet in October.
The numbers are designed to impress, and they do.
But my view is that Europe should resist treating the length of a blacklist as evidence that the sanctions system is working.
The real test is not how many companies Brussels names. It is whether those companies are genuinely cut off from finance, technology, insurance, shipping and the European market—and whether member states enforce the restrictions when their own industries stand to lose.
Brussels moves from industries to individual companies
Unlike earlier packages focused on entire sectors, the proposed measures are being assembled company by company.
The European External Action Service has reportedly spent months identifying businesses that remain connected to Russia’s military-industrial complex but have escaped previous sanctions. This could include manufacturers, distributors, logistics providers and corporate structures used to procure restricted technology or keep Russian supply chains operating.
The approach follows the EU’s recently approved 21st sanctions package targeting Russian banks, energy, cryptocurrency networks and the shadow fleet.
That package added 170 entities and 48 individuals, sanctioned 94 financial institutions and imposed restrictions on third-country banks, crypto platforms, oil traders and companies supplying Russia with dual-use goods. It also expanded the number of listed shadow-fleet vessels to more than 670.
The planned 1,600-company package would dwarf those listings numerically.
Economically, however, officials reportedly accept that it may have less impact than previous restrictions on Russian oil revenues or the banking system. A thousand small or peripheral companies can matter less than one refinery, bank or shipping network positioned at the centre of Moscow’s war economy.
Europe’s enforcement contradiction
The proposal arrives days after the EU was forced to dilute parts of its 21st package.
Greece secured an exemption allowing European operators to continue moving Russian liquefied natural gas to third countries under pre-invasion contracts. France and Italy pushed for a weaker approach to Russian combatants entering the EU, while planned restrictions on some Russian fish imports were removed.
This is not an isolated contradiction.
As EBM reported, Greek shipowners earned billions transporting Russian oil while remaining within the rules Brussels created. The EU wanted to limit Russia’s revenue without removing its oil from the global market, so Western shipping and insurance companies continued servicing cargoes sold below the price cap.
That may have been economically rational. It also demonstrates how sanctions can become a managed system of permitted Russian trade rather than a genuine commercial blockade.
The same tension emerged when Brussels appeared ready to reverse restrictions on a Chinese chipmaker accused of supplying dual-use components to Russia, after European carmakers warned that cutting off the company could disrupt their own production.
Europe’s position was straightforward: punish a company for allegedly helping Russia, until doing so threatened European factories.
A blacklist must have consequences
Targeting individual companies can be effective. Asset freezes, financing restrictions and bans on supplying technology can make it significantly more difficult for businesses to deal internationally.
But companies involved in sanctions evasion rarely operate under one name, in one jurisdiction or through one bank account. Ownership can be shifted, shell companies created and transactions redirected through countries that do not enforce EU restrictions.
The Council has already acknowledged that Russia’s support networks extend through companies based in China, Hong Kong, Turkey, the UAE, Azerbaijan and other third countries. Recent EU measures have targeted drone manufacturers, oil intermediaries and logistics businesses outside Russia itself.
Brussels must therefore pursue the networks behind the names, not merely publish another list.
That means banks identifying connected entities, customs authorities inspecting suspicious shipments and governments prosecuting businesses that deliberately divert restricted goods. It also means resisting political pressure when enforcement damages a domestic company.
Otherwise, the EU risks creating a sanctions regime that is strict against firms without political protection and negotiable for those with strategically important assets.
Europe’s own exposure remains unresolved
The sanctions system is also producing growing legal and financial costs for European companies.
Russia has retaliated by seizing assets, redirecting payments and using domestic courts against Western businesses. EBM’s examination of European banks caught between EU sanctions and Russian asset seizures shows how complying with Brussels can still leave companies exposed to substantial losses in Moscow.
Europe faces a similar dilemma over frozen Russian sovereign assets. Policymakers want to use the money to support Ukraine, but Belgium—where much of it is held—fears being left responsible if the policy generates successful legal claims. The dispute explains why Europe has struggled to mobilise €185 billion in frozen Russian funds.
These are real constraints. But they also underline why sanctions should be judged by outcomes rather than announcements.
The real test comes in October
Blacklisting 1,600 companies would be a major escalation and could close gaps that Russia has exploited for years.
It would also give Brussels another impressive headline.
The distinction between those two things will depend on enforcement.
If the EU unanimously approves the package, pursues associated shell companies, restricts their access to finance and denies them the technology Russia needs, it could materially disrupt parts of Moscow’s military supply chain.
If national governments begin negotiating exemptions as soon as their own commercial interests are affected, the record number will mean considerably less.
Europe does not lack sanctions. It has now adopted 21 packages and listed nearly 3,000 individuals and entities.
What it lacks is a consistently enforced system that applies with the same force in Athens, Paris, Dublin and Berlin as it does against a little-known supplier in Central Asia.
A blacklist of 1,600 companies will look formidable on paper. The question is how many will still be able to trade once the political bargaining begins.


































